Landslides in the Himalayas and storms in the Bay of Bengal are commonplace. Such natural events turn into disasters only when human lives or property is harmed. We now know enough about land and the seas to be wary of the vulnerabilities and limits of human activity in locations such as the coast, hillsides, deserts, floodplains, and riverside. Why then do we still contend with tragedies like the Bhopal gas disaster, the Joshimath land subsidence, or the devastating flash floods in Kedarnath in 2013, or the urban floods in Chennai, Bengaluru, Pune, Hyderabad or Mumbai?
The quality of due diligence exercised by authorities in assessing Tamil Nadu government’s proposal for former and late Chief Minister Kalaignar Karunanidhi’s memorial – a 52-metre ‘Pen Statue’ inside the Bay of Bengal – offers some insights by spotlighting the fault lines that lead to environmental and social disasters.
It is known that the Bay is no placid lagoon to be trifled with. The site chosen for the Pen Statue off Chennai’s famous Marina Beach, is itself a monument to human hubris. In 1881, the British built the breakwaters for the Chennai harbour which interfered with the flow of sediments along the shoreline. As a result, entire villages to the north of the harbour were eroded and swallowed by the sea, while the southern shores grew, permanently and disastrously blocking the Cooum river mouth.
A public hearing for the Pen Statue is scheduled to be held at Kalaivanar Arangam, Chennai, at 10.30 am on January 31, and a draft Rapid Environmental Impact Assessment (EIA) report for the 'Proposed Construction of Muthamizh Arignar Dr Kalaignar Pen Monument in Bay of Bengal off the Coast of Marina Beach' has been published for comments. The 383-page document claims to present the baseline status of the project site, local communities, their livelihoods and the environment (flora, fauna, air, water and sediment quality) in and around the project site, the proposed project’s projected impact on the baseline, and the management measures to be undertaken to mitigate those impacts. But as explained below, the poor quality of the EIA report is itself an insult to Kalaignar’s literary genius.
Until March 2015, statues and monuments inside the sea were not permissible under the Coastal Regulation Zone rules that were created under the Environment Protection Act’s provision empowering the Union government to take “all such measures…for the purpose of protecting and improving the quality of the environment."
The law stood in the way of the Government of Maharashtra’s proposal to erect a statue for Shivaji inside the Arabian Sea. So the law was changed to introduce the following caveat in the list of prohibited activities:
“Reclamation for commercial purposes such as shopping and housing complexes, hotels and entertainment activities [except for construction of memorials/ monuments and allied facilities, only in CRZ-IV (A) areas in exceptional cases, by the concerned State Government, on a case to case basis.”
To make up for the arbitrariness of the exemption, conditions were imposed requiring such proposals to provide “justification for locating the project in CRZ area along with details of alternate sites considered,” submit a full EIA, and undergo a public hearing.
The exemption, though, applies to structures “only in CRZ-IV(A) areas.” The pedestrian pathways and approach structures from the beach to the Pen Statue inside the sea traverse CRZ 1A (turtle nesting grounds), CRZ II (urban coastline) and CRZ IVA (sea). The memorial is not covered by the exemption. But instead of rejecting it at the pre-appraisal stage on legal grounds, “experts” at the state and Union-level and the state environment department appear to have taken a politically expedient decision to entertain the proposal.
Second, a statue can be constructed anywhere on land, including inside the Secretariat. No justification has been provided for locating the project inside the sea. Rather, the alternative site analysis evaluates three sites all of which are inside the Bay of Bengal.
Indian EIAs are notorious for their shoddy science, plagiarised content and fudged and irrelevant data, and for being vacuous despite their size. This EIA provides a case in point. The Terms of Reference for the EIA requires primary baseline data on aquatic flora and fauna, demographics and livelihood, and evaluation of impact of the project on marine life, migratory species, and fishing activity.
No baseline survey for either aquatic flora/fauna or local demographics and livelihood base was carried out. That is like diagnosing and prescribing treatment without even examining a patient. The secondary data presented for plants and animals pertain to the Adyar River, not even the Cooum which empties into the Bay near the project site.
For a project that is to come up inside the sea and on a notified turtle nesting beach, the EIA is peppered with inane conclusions such as this:
“The study area is in non-forest land where presence of fauna is very rare. As such, there will be no adverse impact of the plant unit activity on fauna around the plant unit area.”
The mention of “plant unit” in reference to a memorial project suggests that these sentences may have been lifted from some other EIA report pertaining to a plant (factory).
A marine survey claims to have been carried out between May and July 2021, well before the proposal was even submitted for CRZ clearance. According to the Union Ministry of Environment, Forest and Climate Change’s Parivesh website, the proposal was submitted on August 11, 2022 and the Terms of Reference for the EIA was issued on September 27, 2022. This survey, though, does not present an exhaustive record of flora and fauna. Rather it is arbitrarily restricted to data about bathymetry, marine water and sediment quality, pelagic organisms, sensitive marine species (seagrass, coral reef, exotic fish, etc).
The survey concluded that:
> Seabed was devoid of any sensitive species like coral reefs, seagrass, and Olive Ridley turtles.
> The structures will be built on piles, which will be positioned such that they will not disturb any fishing activities.
> During the survey, no fishing boat movement was observed throughout the project area as well as in the vicinity of the 500 m radius of the proposed Pen Statue.
> No sensitive marine flora and fauna were found in and around the proposed project site.
> The marine water and sediment quality were found to be optimum.
> Plastic bags, wrappers, and PET bottles etc were found floating on the surface.
> Seabed was found clear with better visibility from the midpoint to bottom of the sea bed.
These conclusions fly in the face of what local fisherfolk will tell you about the sea, seabed, and the life that thrives in this region.
For instance, gravid mother turtles visit Chennai’s beaches to lay eggs during the cooler months – between December and March – and not during the summer when the survey was conducted.
The Pen Statue, which will urbanise a prominent turtle nesting coastline, neither acknowledges the coast as a nesting site for a scheduled species nor provides for its conservation.
Contrary to the survey finding, the marine sediment quality is anything but optimum. Even this EIA’s sediment data records that mercury levels in six out of eight samples are at dangerously high levels already. Dredging and construction in such contaminated sediments will resuspend the settled mercury and spread the contamination further afield. The EIA does not discuss any of these possibilities and their impact on the food chain.
The list of fish reported from the Pen Statue site includes fish that do not exist, such as letrius, engraylish lobster and synargis. If the second is a reference to “English lobster,” that makes this site the first to host a species of commercially precious lobster that is restricted to the cold waters of Northeast Atlantic, Mediterranean and Black Sea. The only mention of anything remotely resembling “synargis” in fisheries is of Lutjanus synagris, a variety of snapper found in the western Atlantic. As for Letrius, according to Google, it is a half-destroyed planet in a sci-fi novel titled “Tyrant Robot of Letrius.”
Just as the EIA brings alive fishes never heard of before by the region’s fishers, it invisibilises the richness of the ocean floor in the region, and exposes the authors’ ignorance of the diversity of fishers, fishing methods and their craft and gear.
The report wipes out the presence of fishers from their local seas by claiming that no boats were observed during their survey. Ironically, the survey itself was carried out using a local fishing boat piloted, in all likelihood, by a fisherman who could have helped enrich the EIA with his experiential expertise about the local seas and the coastline.
On December 1, 2022, Urur Kuppam fisher elder S Palayam called me excitedly. “The Chief Minister should visit the beach behind his father’s memorial today. Fishing boats from three districts – Thiruvallur, Chennai and Kanchipuram – are gathered here. There is an unseasonal bounty of shrimp in the kadavadu seru (the muddy seabed) exactly around where the Pen Statue is to come up,” he explained. A memorial should trigger good memories of the departed soul. “This project is a kick to the stomachs of fishers. Stalin should call it off,” he said.
Local fishers also point to the importance of nearshore and shore fishing in the waters behind the Chief Ministers’ memorials to poorer fishers without the means to own boats and gear. Ignoring the importance of such fisheries to the local economy, the EIA report claims that “No fishermen will do fishing within 360 m from the shore. As the shoals of fishes would be available only in the deep venture (sic) of the sea.”
It is common knowledge that in tropical seas, fish are found in the nutrient-rich waters closer to the shore, and it is the coastal waters that are most intensely fished and contested over.
The authors’ failure to study fishing habits and methods is evident in their claim that the project will not interfere with fishing activity as the structure will be built on piles – i.e. there will be a clearance between the Pen Statue platform and the sea. Fishers point out that having structures, especially in the form of concrete columns that support the pedestrian bridge or the monument itself, are a major hindrance. “There are four prominent ocean currents at play here,” Palayam explained. “The olini is a powerful current that flows from east to west – from the sea towards land. Memeri flows in the opposite direction. The Vanni flows from north to south and is the dominant current during the Vaadai season (northeast monsoon). The Thendi currents are southerly currents that characterise the Kachaan season (southwest monsoon). We set our nets as per the prevailing currents, expecting the nets to drift a bit. The proposed structure will block the drift, and the nets will snag on the pillars and be destroyed. Each net may cost anywhere between tens of thousands and several lakhs. Who will compensate the fisher for the damaged net?” asksled Palayam.
The report’s glib denial of easily verifiable facts exposes a disregard not just for the interests of fisherfolk but also for the security of the city. For a maritime metropolis, Chennai’s resilience hinges on a healthy and respectful relationship with the sea. Such a relationship is impossible without respect for the lives and livelihoods of fishers that have the closest connect with the local seas. Far from memorialising the late Chief Minister, Kalaignar’s pen memorial has the power to write over the Dravidian social justice narrative by obliterating marginal geographies and livelihoods.
Nityanand is a Chennai-based writer and social activist. Views expressed are the author’s own.